Jurisdictional defect in reassessment notice: notice issued by the wrong assessing authority was set aside with all consequential proceedings.

A reassessment notice issued under section 148 by the Jurisdictional Assessing Officer, instead of the statutorily mandated Faceless Assessing Officer, was treated as jurisdictionally invalid. The Court followed its existing binding decision on the same point, noting that there was no stay and judicial discipline required adherence to that precedent. The notice and all consequential proceedings were set aside in favour of the assessee.

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Issues: Whether a notice under section 148 of the Income-tax Act, 1961 issued by the Jurisdictional Assessing Officer, instead of the Faceless Assessing Officer, was liable to be set aside.

Analysis: The challenge to the reassessment notice was treated as covered by an existing binding decision of the Court on the same point. In the absence of any stay of that decision, judicial discipline required the Court to follow it and not keep the matter pending.

Conclusion: The notice under section 148 and all consequential proceedings were set aside in favour of the assessee.

Ratio Decidendi: Where a notice is issued contrary to the statutorily mandated authority, the defect is jurisdictional and the notice cannot be sustained.

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